ETNO Expert Contribution in response to the Consultation to develop an RSPG Opinion on World Radiocommunication Conference 2007

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1 May 2004 ETNO Expert Contribution in response to the Consultation to develop an RSPG Opinion on World Radiocommunication Conference 2007 Executive Summary: ETNO is pleased to provide its early views on agenda items and strategies for the next World Radiocommunication Conference in Positions expressed at this early stage of the WRC 07 preparation are subject to further refinement. From the network operators point of view, the WRC 07 agenda items related to spectrum for the Mobile Service, i.e. UMTS/IMT 2000 and systems beyond, are the crucial ones. In addition other agenda items, e.g. related to the Fixed Service, are also relevant for ETNO members. For the benefit of citizens and economies of scale, the provision of sufficient harmonised spectrum for innovative radio services and adequate protection of existing radio applications should be the general objective. An open and transparent preparation process as established in CEPT with industry participation at all levels is considered as the best way to achieve results for the benefit of all parties concerned. Introduction and general comments ETNO represents the voice of 41 of Europe s largest, well established telecommunications operators in 34 countries. ETNO welcomes this early Commission initiative in support of the CEPT preparation, and is pleased to submit its initial comments to the consultation in the context of the development of an RSPG Opinion on Community priorities and objectives for the World Radiocommunication Conference ETNO would be pleased to discuss this issue further with the RSPG should this be considered appropriate. The ETNO preparation of WRC 2007 is still at an early stage. So far, we have identified agenda items relevant for network operators and started to develop preliminary positions for them. Therefore, positions expressed in this paper on specific topics are subject to further refinement later in the preparation process. ETNO Expert Contribution EC062 (2004/05) 1

2 ETNO views on the RSPG questions 1) What are the agenda items at WRC 07 (to be specified by the respondent) which potentially could have a significant positive or negative impact on common European policies and on important pan European industrial sectors? Almost all or even all agenda items of WRC 07 have an impact on common European policies and pan European industrial sectors, with differing significance for European citizens thereof. However, for directly affected industries the relevance is of course high. The WRC 07 agenda items of interest for ETNO members are mentioned below. Mobile issues (WRC 07 agenda items 1.4 and 1.9) These two agenda items are considered as the basis for the future development of mobile communications. A clear and predictable regulatory environment is needed to attract and encourage investments in the mobile sector. In that respect, items 1.4 and 1.9 cover important medium to long term issues regarding 3G, such as the protection of terrestrial UMTS/IMT 2000 in the band MHz designated as an extension band for UMTS/IMT 2000, and the consideration of frequency related aspects for future developments of UMTS/IMT 2000 and systems beyond IMT Fixed Service related issues (WRC 07 agenda items 1.17, 1.18, 1.19 and 1.8) These agenda items impact the operation of terrestrial communication networks related to the information society on one hand and of the European satellite industry and the European space policy on the other hand. The further development of FSS applications and HAPS is followed with interest by telecommunication operators as a possible complement to the other technical platforms (e.g. optical fibre, ADSL, radio relay, FWA, etc.). However, when identifying additional spectrum for FSS or HAPS, due account should be taken of the protection of existing radio services like the Fixed Service. Other agenda items in which ETNO is interested in Other topics with the potential to affect communications services are contained in WRC 07 agenda items 1.5, 1.6, 1.7, 1.11, 1.12, 1.14 and In addition agenda items 7.1 and 7.2 are of importance. ETNO Expert Contribution EC062 (2004/05) 2

3 2) Which are the broad objectives which Europe could set itself for these agenda items, bearing in mind that many technical constraints are not yet clarified, and the fact that non European interests might not support such objectives during the negotiations? The general objective should be to make available sufficient spectrum for innovative services while ensuring adequate protection of existing services from harmful interference. Results in that sense will benefit citizens as well as economies of scale. Mobile issues Agenda item 1.4: This agenda item covers two aspects, the extension of coverage to allow cost efficient operation of UMTS/IMT 2000 services and the evolution of IMT 2000 towards higher bit rates in order to provide enhanced multimedia mobile services. Regarding the extension of IMT 2000 coverage, the objective at this stage should be to study frequency bands lower than those currently identified for the coverage of large areas of low population density. The results of RRC 04 and RRC 06 and the need for harmonisation of the digital dividend (where available) should be taken into account, with the aim of taking a decision at WRC 07 on a worldwide identification. Concerning high bit rate mobile services, one should study the market needs and the evolution of services, with the aim of taking a decision for identification of frequency bands for IMT 2000 and systems beyond at WRC 07 or a following Conference, depending on market demand. Agenda item 1.9: CEPT has identified the band MHz as the primary extension band for UMTS/IMT 2000, in response to Commission Mandate 4. CEPT has recently taken the decision to designate the whole IMT 2000 extension band to terrestrial UMTS/IMT 2000 in response to the Commission Mandate 5. From the European point of view, the objective of this agenda item is to protect terrestrial UMTS/IMT 2000 in this band from satellite interference to ensure its future deployment. This objective should be reached on a global basis. Another objective is to ensure that no constraints are imposed on terrestrial UMTS/IMT 2000 in view of protecting satellite services. The results already achieved at WRC 03 corresponding to the protection of terrestrial IMT 2000 from BSS sound interference should also be secured. Besides European contributions to technical studies, policy support by the Commission is considered to be beneficial to represent European interests for global availability of the band MHz for IMT 2000 in the ETNO Expert Contribution EC062 (2004/05) 3

4 negotiations (e.g. bilateral meetings with Japan and China) prior and during the Conference, respectively. Fixed Service related issues (WRC 07 agenda items 1.17, 1.18, 1.19 and 1.8) Agenda item 1.17 As the European interest for NGSO feeder links at 1.4 GHz is low, the European objective for agenda item 1.17 should be the protection of the fixed service in the bands around 1.4 GHz. These bands are used, due to their favourable propagation properties, for the provision of fixed wireless access to customers located in rural and sparsely populated areas. Agenda item 1.18: The frequency range GHz is heavily used by Fixed Service applications in Europe. Therefore, the adequate protection of these operations should stand in the forefront from European perspective. Agenda item 1.19 Although broadband satellite applications are considered as a possible complement to other communication platforms (e.g. optical fibre, ADSL, radio relay, FWA, etc.), due account should be taken of the protection of existing radio services like the Fixed Service. Topics with the potential to affect communications services (WRC 07 agenda items 1.5, 1.6, 1.7, 1.11, 1.12, 1.14 and 1.20) From the communications operators point of view, these agenda items have to be followed carefully, in order to ensure that the regulatory decisions taken to promote the considered services or applications including simplifications of coordination procedures do not threaten our interests. 3) Is it currently foreseeable that there could be contrasting requirements for different Community policies which would need to be interpreted preferably before the WRC 07 negotiations? If so, where? There could be conflicts if the spectrum demand to fulfil different Community policies is focussed on the same frequency bands. Some agenda items are generally dealing with the same frequency ranges, but so far differing subbands are considered/investigated. ETNO Expert Contribution EC062 (2004/05) 4

5 4) How to effectively promote at the conference and within ITU the Common Proposals on spectrum selected by Europe in other regions of the world, in order to enable European industry and consumers to benefit from lower barriers to trade and greater economies of scale? The promotion of European positions prior to the Conference is already practised by CEPT in a good manner by close liaison with other regional organisations. Bilateral meetings with other countries/regional organisations are very important to effectively present, explain and support the European positions. This process could be enhanced by policy support from the Commission. Commission policies should be developed in an open, transparent manner, with industry participation, too. 5) How to ensure that generic regulatory principles enshrined in Community legislation for various spectrum using sectors are supported in the WRC 07 process, and notably the principles of technology neutrality, fair competition, regulatory transparency, non discrimination and proportionality, as well as the optimisation of spectrum use? The best approach to achieve this goal is to establish positions at the earliest possible stage of the WRC 07 preparation. These positions should be developed in an open, transparent manner, with the participation of the affected spectrum users and industry. The regulatory principles mentioned in the question are generally supported by the WRC approach. Worldwide harmonisation of frequency bands in order to foster the development of services for the overall benefit should be the main objective of WRCs. 6) What should be the strategy approaches before and during the conference for European delegations to optimise the possibility to reach the aboveidentified common European objectives? Should some European Common Proposals be mandatory for EU members? The coordination organised by CEPT before and during the Conference has proved to be very efficient. Potential conflicts are identified at an early stage of the CEPT preparation of WRCs. Resolution of these conflicts should be preceded by public consultation and should make full use of the CEPT studies, both regulatory, technical and, when appropriate, market analysis. The detailed and extended preparation process leads to European Common Positions which are generally supported by most CEPT members. ECPs that are important for the European Community should be preferably supported by all EU Member States. This should be generally achievable, at ETNO Expert Contribution EC062 (2004/05) 5

6 least on a consensus basis. ECPs should not be made mandatory, but if one or some EU Member States would not be able to commit themselves because of specific national circumstances, they should not undermine these ECPs during the Conference. Regular information meetings during the Conference help to maintain the coherence between different country positions. 7) Are the current procedural arrangements for the European WRC preparations, such as participation to and scheduling of meetings, drafting of European Common Positions and Briefs, availability of information, etc., appropriate? If not, please suggest ways to improve this process. From industry point of view, the open and transparent manner of the WRC preparation in CEPT, where industry is directly participating in the CPG and its Project Teams, is very constructive. It allows a full dialogue and ensures the development of strong CEPT positions and their presentation at the WRC. Any necessary changes during the Conference should take place in the same manner. Only with this approach all parties concerned are able to contribute to the preparation work and the final results take into account everyone s interests. ETNO appreciates the openness and transparency initiated with regard to the work of the RSPG during the last months, and we are looking forward to a wider collaboration in the future. 8) If applicable, please indicate your early views on issues Europe could propose to be included in the agenda for the next conference after WRC 07. Some items on the preliminary agenda for WRC 10 which may impact communication services are already identified as relevant for ETNO, e.g. on the future evolution of mobile communications, on the development of nomadic applications and on the convergence between Fixed, Mobile and Broadcasting services. Due to the fast moving market and technology developments, additional topics might become necessary to be considered at WRC 10. There are a number of issues currently under consideration, e.g. addressing the improvement of the international spectrum regulatory framework. However, ideas are not sufficiently mature for a view to be expressed at this stage. ETNO Expert Contribution EC062 (2004/05) 6